Villain

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VILLAIN., An epithet used to cast contempt and contumely on the person to whom it is applied.
     2. To call a man a villain in a letter written to a third person, will entitle him to an action without proof of special damages. 1 Bos. & Pull. 331.

A Law Dictionary, Adapted to the Constitution and Laws of the United States. By John Bouvier. Published 1856.